Privacy policy

25th HOUR COMMUNICATIONS, INC. PRIVACY POLICY

Company Information

25th Hour Communications, Inc., (the “Company” or “we” or “us” or “our” or “25th Hour”), takes your personal privacy seriously and is committed to the transparent processing of non-confidential information provided to us.  This Privacy Policy outlines our approach to your privacy and applies to all Services we offer to Clients including direct mail services, our website (“Site”), and other services we offer (collectively, “Services”).  This Policy is subject to change and we ask you return periodically to review our position and approach to privacy.   Should you have questions, comments or concerns, please contact us opt-out@25comm.com  

Customers and website visitors (collectively referred to as “Users”) provide us with various types of information and this policy explains how we handle it. Additionally, Clients who use our Services will also provide us with Your Personal Information to create various direct advertising and to fulfill other Services for them.  We work hard to protect the personal information we have access to and will use it only in providing our Services.  We obtain information from our business partners, advertisers and Users in several ways, including but not limited to; third-party mobile applications, videos, mobile websites, desktop sites, banners, landing pages, pixels, self-reported information, ad-tags, analytics tracking and reporting. 

 

Collection of Information

25th Hour Communications, Inc., is a full-service advertising and marketing strategy agency operating across various digital and print platforms.  Currently focused on higher education institution advertising, we work with all growth-related businesses.    A portion of these services offer mobile advertising services and other services which facilitate transactions between educational entities, potential students, current students and others with business partners, brands, small businesses, app developers and ad exchanges (collectively “Clients”).  In connection with service providers and other data partners (collectively “Partners”), Clients use our Services to deliver advertising and information which is of potential interest to them.   

We may (but do not necessarily, or always) collect a variety of information about Users (whether through Users providing the information to us, information provided through various digital platforms or through other partnerships and tools such as Client-facing APIs), including:

·         IP addresses, from which geographic location may be inferred, as well as system configuration information such as information about Users’ operating system;

·         Precise geolocation information (generally as User’s latitude and longitude data);

·         Mobile advertising identifiers, such as iOS IDFAs and Android Advertising IDs (collectively, “Mobile IDs”). These Mobile IDs may be associated with other information we collect through our platform, from third parties, or through any other services we offer;

·         Apps that You have installed, mobile websites that you have interacted with, and how you interact with them, including whether and how you interact with ads (including time-stamp information);

·         Device type and other device information (e.g., whether you are using a smartphone or tablet, and related information);

·         Network provider;

·         Mobile browser (e.g., Firefox, Safari, and Chrome);

·         Carrier user ID (a number uniquely allocated to you by your network provider);

·         Other unique identifiers that may be associated with a Users’ device, including identifiers provided by Clients or their service providers; and

·         Email addresses

As a general rule, we do not collect Personal Information (defined below) on our Site for purposes of sending you direct mail about our business.  Instead, we work with  business partners who provide us your Personal Information and we, in turn, create direct mail (both digital and print)  on their behalf.  In addition, we sometimes solicit information via surveys and other mechanisms to collect data which is then used in the aggregate to make marketing decisions on our Clients’ behalf.  “Personal Information” means identifying information such as your name, postal address, email address or telephone number.

Additionally, you may elect to submit information (including Personal Information) to connect with or do business with us or to respond to informational requests.  Users are responsible for ensuring the accuracy of Personal Information that is submitted through the Site.

Use of Collected Information

We will not share or disclose your Personal Information and/or Non-Personal Information to anyone except as described in this Privacy Policy.

We use Personal Information provided by our Clients and other business partners together with Non-Personal Information we collect through Cookies and other sources to create direct mail, advertising and marketing services on our Clients’ behalf. This includes use of collected information for purposes such as:

·         To send direct mail (whether digital or print) on behalf of the Client who provided such information to us;

·         To develop and create inferences about users categorized into various segments or to help Clients do so;

·         Develop and use data models that try to predict an individual’s potential behavior and interests;

·         Analyze various digital advertisements and their performance;

·         Resolve identities across multiple devices, such as to match IP addresses or emails to link a User across, for example, mobile browsers, mobile devices, tablets, set top boxes, or other devices; and

·         Combine the Service Information to perform (including by working with Clients and business partners) any of the above functions, or other advertising, marketing, or analytics services. Or, we may aggregate and create data models to do this, by creating algorithms to predict common interests among Users. We may provide Users’ email addresses (which we generally annonymize) to Clients that match this information to online cookies or Mobile IDs in their system and tie the information or associated IDs to additional interest-based or demographic data about Users. This may be done, for example, to target advertising or provide analytics to other parties.

·         If you are a Client, or have a business relationship with us, such information may be used for related purposes such as contacting You regarding your requests, billing or other Client/User relationship issues.

 

Sharing and Distribution of Collected Information

Our business partners have authorized us to use your Personal Information, and our use of your Personal Information is, at all times, also subject to the privacy policies of our business partners. Should you wish to learn more about our business partners policies or to update your information, please visit: 

Facebook/Instagram Privacy Policy: https://www.facebook.com/legal/FB_Work_Privacy

Google Privacy Policy: https://policies.google.com/privacy?hl=en

Pandora Privacy Policy: https://www.pandora.com/privacy

Spotify Privacy Policy: https://www.spotify.com/us/legal/privacy-policy/

Snapchat Privacy Policy: https://www.snap.com/en-US/privacy/privacy-policy/

Digital Dynamics 360 Privacy Policy: https://www.digitaldynamics360.com/privacy

If You do not want us to use your Personal Information as provided in this Privacy Policy, you should not submit your Personal Information to us or our business partners through any website, application, or form requesting Personal Information.

From time to time, we may use Non-Personal Information to conduct online research surveys through email invitations, pop-up surveys, and online focus groups (together, “Surveys”) for our internal use. When participating in a Survey, we may ask you to enter Personal Information. The Personal Information you submit in a Survey may be used by us and/or other third parties for various reasons including research, to measure the effectiveness of our Services and/or services offered by our business partners. When our Surveys collect Personal Information, we will not knowingly accept participants who are under the age of 13. Surveys conducted by or on behalf of us will contain a link to this Privacy Policy. If your web browser is not enabled to accept Cookies, you may not be able to participate in some Surveys.

We may use Non-Personal Information in the aggregate to improve our Services and for business and administrative purposes. Non-Personal Information that we collect about you may be combined by us with other information available to us through third parties for research and measurement purposes (collectively referred to as “Collected Information”), including measuring the effectiveness of our Services and/or services offered by our business partners. This information from other sources may include age, gender, demographic, geographic, or other information. We may also use or share any such aggregated data that does not contain Personal Information with third parties for any purpose.

We may share the Collected Information with Clients and Partners in order to provide:

·         Clients and their marketing and service providers, so they may provide targeted content and advertising to Users on mobile websites and/or apps;

·         Other third parties that target advertising. This may include, for example, platforms that work directly with marketers, analytics companies, data management platforms that help marketers maintain and use data, proximity solution providers, and other advertising technology providers. These companies may, for example, provide targeted content and advertising to Users and others on third-party mobile websites and/or apps or other advertising media (such as email, direct mail, and display media);

·         Clients and their marketing and service providers, to help measure the effectiveness of marketing or analyze their Users’ likely interests or demographics;

·         Partners to enhance consumer privacy, or send advertising offers by email or display advertising (which may be linked to a cookie); and

·         Third-party platforms to help advertisers identify common users across different mobile devices and/or mobile browsers.

The processes we described above often involve cookies or similar technologies, which may be associated with other information about Users, such as Users’ interests, demographics, or transactions. This is generally known as “interest-based advertising.”

We may also share Service Information with third parties:

·         Pursuant to a request or authorization by a  User or Client;

·         If the disclosure is provided to: (a) comply in good faith with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas, including for purposes of national security and law enforcement; (b) enforce our terms and conditions or other agreements; or (c) protect our, or any other person’s or entity’s, interests, rights, property, or safety, or in connection with an investigation of suspected or actual unlawful activity;

·         Where the information is aggregated or de-identified; and

·         As part of a business purchase, sale, merger, consolidation, investment, change in control, transfer of all or substantially all of our assets, reorganization or liquidation, bankruptcy, or in connection with steps taken in anticipation of such an event (e.g. due diligence).

Use of Cookies and Pixel Tags, and Other Technologies

Cookies are small data files containing a string of characters, such as unique browser identifiers. Cookies are stored on your computer or other device and act as unique tags that identify your browser. When you visit, we also collect information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. This information is not personally-identifiable.

We, alone or with our Clients and Partners, may use cookies to, for example, “remember” you, track trends, and collect information about how you use our Clients’ or Partners’ websites or interact with advertising. We, and our Clients and Partners, use cookies to provide relevant content to you and replace non-relevant ads with ads that better match your interests. 

Pixel Tags, similar to cookies, are invisible and used when You access certain web pages.  The tag may tell us of the visit to that page and to track activity on a website.  Pixel tag can work in conjunction with cookies.  If You disable cookies, the tag simply detect that a page was visited. 

Other technologies may be used in connection with Services we offer (either alone or in combination with cookies or pixel tags) to collect non-personal information about your system, browser type, domain, system settings and IP address. 

PIXEL TAGS

A pixel tag (also commonly known as a web beacon or clear GIF) is an invisible 1 x 1 pixel that is placed on certain web pages. When you access a web page with a pixel tag, the pixel tag may generate a generic notice of the visit, and permit us, or our Clients or Partners, to set or read cookies. Pixel tags are used in combination with cookies to track the activity on a website by a browser on a device. If you disable cookies, pixel tags simply detect a given website visit.

 

OTHER TECHNOLOGIES

We collect several types of information from cookies and other technologies. For example, we may collect information about the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices used to identify and communicate with each other on the Internet.

Our Clients or Partners may use the above technologies (sometimes, in combination with each other or other data such as IP addresses or de-identified data files) to coordinate identifiers across platforms, browsers, or devices, to more efficiently analyze or target advertising.

Updating Personal Information and Opt-Out

In most cases, you have control over whether or not You would like to receive relevant ads and marketing email from our Clients.

1.      Opting Out of Cross-App Advertising on Mobile Devices

You can opt out of having your mobile advertising identifiers used for certain types of interest-based mobile advertising (also called “cross-app advertising”), including those performed by 25th Hour Communications, Inc., by accessing the settings on your Apple or Android mobile device, as follows:

·         Apple Devices: If you have an Apple device, you can opt out of most cross-app advertising by updating to iOS 6.0 or higher and enabling “Limit Ad Tracking.”

o    iOS 7 and Higher: Go to Settings → Privacy → Advertising, and toggle “Limit Ad Tracking” to ‘ON.’

o    iOS 6: Go to Settings → General → About → Advertising, and toggle “Limit Ad Tracking” to ‘ON.’

·         Android Devices: If you have an Android device, you can opt out of most cross-app advertising by going to Google Settings → Ads and selecting the option to opt out of interest-based ads.

The above instructions may change, and You should contact your device manufacturer for the most up to date information.  Further, if your device uses other platforms not described above, please check the settings for those devices.  You may also contact the advertiser directly and ask to be opted out of their emails.

If You desire to update any Personal Information you have provided to any of our business partners or to change your preferences, please review the privacy policy of such business partner.

You may opt out from receiving promotional emails from us, such as emails to inform you about events and new services, by following the “unsubscribe” instructions in any promotional email you receive, or by contacting us at: opt-out@25comm.com

Data Access and Retention

We offer our Services and maintain our data exclusively in the United States. Our Services are not offered to or directly track users’ behavior in the European Union. While your data may be transferred in and out of the United States, such transfer is only for routing of data, not use or storage of data. By using the Site or any other of our Services, you consent to the collection, processing, maintenance, and transfer of all information under the laws of the United States. 

Third Party Websites and Apps

This Policy only applies to the 25th Hour Website. We are not responsible for the privacy practices or disclosures of websites, developers, or apps that access or use the 25th Hour Website. Likewise, when you access the 25th Hour Website, if you are directed to other websites, please know that we do not control such websites or how they use Your information.   We encourage you to read the applicable privacy policies and terms and conditions of such third parties and websites, and the industry tools that we have referenced in this Policy.

California “Do Not Track” Statement

We do not currently recognize or respond to browser-initiated Do-Not-Track signals, as there is currently no industry-wide consensus as to uniform Do-Not-Track standards, implementations, or solutions.

Children’s Privacy Policy and Parental Controls

We do not solicit any Personal Information from children, and our Services are not directed to children younger than 13 years old. If you are not at least 18 years old, you are not authorized to use the Site.

 

Effective Date of This Policy.

Effective date of this Privacy Policy is July  15, 2019 and was last updated on July 15, 2019.  This Policy may change from time to time and you are encouraged to review this periodically.  While we will attempt to notify Users via a pop-up or other digital device that this Policy has changed, it is your responsibility to check back often.